NBAA has secured a limited exemption for certain association members from the FAA requirement to begin reporting pilot records created on or after June 10 to the Pilot Records Database (PRD) within 30 days. The exemption applies to NBAA member companies conducting Part 91K and 135 operations that hold OpSpec A025 or MA205, respectively, for electronic training records.
According to NBAA, the exemption provides relief only from the reporting requirements outlined in FAR 11.215(a) and expires Jan. 10, 2023. NBAA requested relief because the PRD proposed rule indicated that the FAA would provide two methods of data entry into the PRD: electronic transmission or manual entry. However, NBAA noted that the electronic transmission method is not expected to be ready until later this year.
“Some NBAA member companies deal with high volumes of pilot records, and asking them to submit records manually is not only inefficient, but it also creates accuracy concerns,” said Jason Maddux, principal at Garofalo Goerlich Hainbach and vice-chair of NBAA’s Regulatory Issues Advisory Group. “Manually submitting large volumes of data introduces a human-error risk and defeats the purpose of the PRD, which is to improve safety by providing potential employers with accurate pilot records.”
Qualifying entities must submit a letter of intent to the federal e-rulemaking portal through the comment process under Docket FAA-2022-0795.